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Wintermute Trading Ltd. Terms of Use

Last Updated: November 11, 2025

1. Introduction

This is a contract between you and Wintermute Trading Limited ("Wintermute") a company organised and existing under the laws of England and Wales with company number 10882520 and having its registered office at Colegrave House, 70 Berners Street, London, Westminster, W1T 3NL, United Kingdom. Wintermute is registered with the Financial Conduct Authority ("FCA") as a cryptoasset service provider, with FCA firm reference number 928764.

In this document, references to we/our/us are to Wintermute. Any references to Customer/you/your are references to you as a customer of Wintermute and user of our services.

This Agreement applies to your use of the following Wintermute products and services (the "Service" and "Services") only:

  • The ability to sell Cryptocurrency through our Off Ramp products ("Ramps Services");

Please read this document carefully, as it sets out the terms and conditions on which Wintermute will provide the Services to you.

By agreeing to these terms and using our Services, you agree that you have read and understood, and that you accept, all of the terms and conditions contained in this Agreement.

This Agreement will govern the use of the Services provided by Wintermute. By using the Services you agree to be bound by the terms and conditions of this Agreement. If you do not agree to any of the terms in this Agreement, or any subsequent modification to this Agreement, you will not be permitted to use the Services. This Agreement will come into effect when you confirm electronically that you agree to it. We recommend that you retain a copy of this Agreement and transaction records.

We may from time to time make changes to the terms of this Agreement. Unless specifically indicated otherwise, any change will take effect immediately when the revised Agreement is posted through one of our communication channels (such as our website or mobile or desktop applications, if applicable). We will strive to provide you with advance notice of material changes to this Agreement where possible through email or a notification through the Wintermute platform. Your use of the Services after the effective date of a change to this Agreement means you have read and accepted these changes. If you do not agree with any changes to this Agreement, you must stop using or close your Wintermute Account.

You may need to accept additional terms in order to use our Services, including terms and conditions of third parties that we may integrate or partner with ("Third Party Partners"). Your agreement with such third parties will govern the terms and conditions of products or services provided by any third parties. We are not responsible for the products or services provided to you by any third party.

If you are using the Services on behalf of a company, organization, or other legal entity (a "Business"), you represent and warrant that you are authorized to bind that Business to these Terms, and that you accept these Terms on behalf of the Business. In this case, references to "you" and "your" shall mean both you as an individual and the Business on whose behalf you are acting.

Use of cryptocurrency may be illegal in some jurisdictions. It is your responsibility to know the regulatory requirements concerning transactions with cryptocurrency in your jurisdiction before using the Services.

Definitions

For the purposes of this Agreement:

  • an "Account" or "Wintermute Account" means an online account created by you in order to access the Services;
  • a "Business Day" means any day which is not a Saturday, Sunday or public holiday in the United Kingdom and which the banks are open for business in the United Kingdom;
  • "Cryptocurrency" or "Cryptocurrencies" means a cryptographically secured digital representation of value or contractual rights that uses a form of distributed ledger technology and can be transferred, stored or traded electronically. The definition of Cryptocurrency also includes "right to, or interest in, the Cryptocurrency";
  • "Order" means a request for the Services;
  • "Partner" means third party firms who refer you to Wintermute in order to sell Cryptocurrencies;
  • "Partner Sites" means Partner's mobile applications and websites;
  • "Services" means services offered by Wintermute;
  • "Wallet" means a secured digital facility in which Cryptocurrencies are held; and
  • "Wallet" means a non-custodial Wallet

Disclaimer

You have understood, acknowledged and accepted the following DISCLAIMER:

The risk of loss in trading or holding Bitcoin or any other Cryptocurrency can be substantial. You should therefore carefully consider whether trading or holding Bitcoin or any other Cryptocurrency is suitable for you in light of your financial condition. In considering whether to trade or hold Cryptocurrency, you should be aware that:

  • When you buy, sell or transfer Cryptocurrency you are dealing with a digital asset. This means that, like any other digital system, Cryptocurrencies are at risk of being hacked or affected by technical problems. This could result in you losing your Cryptocurrency or delay your ability to sell, transfer or spend it;
  • The price or value of a Cryptocurrency can change rapidly, decrease and potentially even fall to zero. Factors that may affect the value of a Cryptocurrency include a change in governing regulation, introduction of new Cryptocurrencies, or a change to how a Cryptocurrency works.
  • You acknowledge that Wintermute is not responsible for safeguarding or holding your Cryptocurrency, or any private keys or other security information needed to access your Cryptocurrency and that Wintermute is not responsible for any loss of Cryptocurrency resulting from theft, loss, or mishandling of Cryptocurrency private keys or other security information outside its control.
  • Every sale of Cryptocurrency is effected on and confirmed by the respective network of that Cryptocurrency. The confirmation takes a period of time (usually less than one hour, but possibly one day or more). An Order is not complete until it is confirmed by the relevant network. Cryptocurrency associated with Orders that are in a pending state will be designated accordingly.

In the United Kingdom, our Services are not covered by the Financial Ombudsman Service or the Financial Services Compensation Scheme.

2. Eligibility

To be eligible to use any of the Wintermute Services, you confirm that you:

  • are at least 18 years old;
  • have sufficient capacity to enter into legally binding contracts;
  • reside in a country in which the relevant Wintermute Services are accessible; and
  • are willing to provide to us any current valid personal identification documents that we request.

3. Services provided to you

Once you have completed the registration process (as set out at clause 4 below), Wintermute will provide the Services to you.

When using the Services, you are buying Cryptocurrency from, or selling Cryptocurrency to, Wintermute directly to the extent such transaction does not expressly involve decentralized finance ("Defi") functionality. In the event a transaction does expressly involve Defi functionality, Wintermute acts as merchant of record only with respect to (i) any portion of the transaction that directly involves fiat currency; whereas all other Defi activities are conducted onchain between you and other market participants on a peer-to-peer basis.

Wintermute does not act as an intermediary or marketplace between other buyers and sellers of Cryptocurrency. Wintermute will send / deliver Cryptocurrency to the Wallet address indicated at the time of the Order subject to the conditions of this Agreement;

At no point during the sale, will Wintermute be in possession or in control of client funds. Wintermute does not host Wallets, and is not a custodian of your funds or assets; and Orders through Wintermute are executed individually, one by one.

Wintermute DOES NOT facilitate or provide trading or investment or brokerage accounts or facilities, nor does Wintermute provide investment or any other financial advice.

4. Customer registration process

To use the Services, you will need to register for an Account, complete Know Your Customer protocol, and accept the terms of this Agreement. You will also need to self-categorise and complete an appropriateness assessment.

By using Services, you agree and represent that you will use the Services only for yourself, and not on behalf of any third party. Upon successful completion of the registration process, Wintermute will establish your Account.

You are fully responsible for all activity that occurs under your Wintermute Account. We may, in our sole discretion, refuse to open a Wintermute Account for you, or limit the number of Accounts that you may hold or suspend or terminate any Account, and are not required to provide you with the reasons for taking any such action.

As part of the registration process, you must provide Wintermute with the information that is requested as part of the Account opening process to identify and verify your identity and for the detection of anti-money laundering, terrorist financing, fraud, or any other financial crime and permit us to keep a record of such information. You will need to complete certain verification procedures before you are permitted to start using the Services.

The information we request may include certain personal information including, but not limited to, your name, address, telephone number, email address, date of birth, government identification number, information regarding your bank account (such as the name of the bank, the account type, routing number, and account number) network status, customer type, customer role, billing type, mobile device identifiers (IMSI and IMEI) and other subscriber status details.

In providing us with this or any other information that may be required, you confirm that the information is accurate and correct and you agree to keep us updated if any of the information you provide changes. You authorise us to make enquiries, whether directly or through third parties, that we consider necessary to verify your identity or protect you and/or us against fraud or other financial crime, and to take action we reasonably deem necessary based on the results of such enquiries.

When we carry out these enquiries, you acknowledge and agree that your personal information may be disclosed to credit reference and fraud prevention or financial crime agencies and that these agencies may respond to our enquiries in full. This is an identity check only and should have no adverse effect on your credit rating.

Additionally, we may require you to wait some amount of time after completion of a transaction before permitting you to use further Services and/or before permitting you to engage in transactions beyond certain volume limits.

Failure to provide any information that Wintermute reasonably requests from you after you have become a Customer may be grounds for the suspension of the provision of Services to you (including access to your Account) and/or the termination of this Agreement. The nature and extent of the information you are required to provide may differ, for example, based on the Services provided to you under this Agreement and/or the means of payment you use.

5. Transaction limits and enhanced due diligence

The use of all Services is subject to a limit on the volume, stated in GBP, you may transact or transfer in a given period (e.g. daily). Your transaction limits may vary depending on your payment method, and other factors.

We reserve the right to change your transaction limits as we deem necessary and where possible will provide advance notice to you, although in some cases this will not be possible and you will be informed after any changes to the applicable limits have taken place.

If you wish to raise your limits beyond the posted amounts, you may submit a request to support@Wintermute.com

We may require you to submit additional information about yourself and provide additional records, if you wish to raise your limits ("Enhanced Due Diligence"). In our discretion, we may refuse to raise your limits, or we may lower your limits even if you have completed Enhanced Due Diligence.

6. Cryptocurrency orders

You will be able to sell Cryptocurrencies to us, through our Services subject to any applicable fees and limits.

Wintermute may charge fees for your use of the certain Services. Wintermute reserves the right to adjust its pricing and fees and any applicable waivers at any time.

Cryptocurrency sales shall be debited from the Cryptocurrency Wallet provided by you at the time of the Order, as soon as possible once the Cryptocurrency sale has been confirmed by the Cryptocurrency network. Once the Cryptocurrency sale is confirmed, fiat funds will be credited to the Customer's bank, card provider or other relevant party.

If we allow you to set up a recurring sale of Cryptocurrencies (each, a "Future Transaction"), you authorise us to initiate recurring electronic payments in accordance with your selected Cryptocurrency Order. Your Future Transactions will occur based on your authorisation selection until either you or Wintermute cancels the Future Transaction. This authorisation will remain in full force and effect until you change your Future Transaction settings or until you provide us with written notice via support@Wintermute.com

Please note that as part of accessing our Services, you may be required to sign up to separate and independent terms when using the Partner Sites and with any third-party payment processor.

You agree that you are solely responsible and liable for keeping your Wintermute Account safe and secure and for maintaining adequate security and control of your login and authentication details (including, but not limited to, your identity, and username). You agree you are solely responsible for any access to and use of the Services and your Wintermute Accounts, notwithstanding that such access or use may have been effected without your knowledge, authority or consent. You are solely responsible for all orders that occur using your Wintermute Account.

We will endeavour to let you know in advance if we decide to stop offering a Cryptocurrency. But it may not always be possible to give you advance notice, for example if a Cryptocurrency becomes illegal due to a sudden change in applicable laws and regulations or if a Cryptocurrency suddenly changes the way it functions or its name.

7. Cryptocurrency storage

Wintermute does not provide any Wallet or hold, safeguard or administer any private keys or other security information or Cryptocurrency for its Customers.

When using the Services, you will be asked to provide us with the address for your Wallet by connecting and signing ownership of your Wallet.

It is your responsibility to provide us with a true, accurate and complete Wallet address when carrying out an Order. It is therefore important that the Wallet address that you provide for an Order is correct. You understand and agree that Wintermute accepts no liability for you providing an incorrect or inaccurate Wallet address as part of an Order.

By providing a Wallet address to us, you confirm that this is the Wallet address that should be used for the relevant Order and we will not, and have no responsibility to, check whether you have provided a correct and accurate Wallet address for the Order.

You acknowledge and agree, without prejudice to any other terms in this Agreement, that you bear all of the risk of any loss of access to your Wallet(s) and any Cryptocurrencies contained in your Wallet(s). Wintermute does not control and is not responsible for the Cryptocurrencies in your Wallet(s). You are solely responsible for any Cryptocurrencies transferred to or from your Wallet(s) and we make no, and hereby disclaim all, representations, warranties, claims and assurances as to any such transactions.

If you lose your keys to your Wallet(s), you may lose access to your Wallet(s) and any Cryptocurrencies contained in your Wallet(s). Wintermute is not liable for fluctuations in the fiat currency value of Cryptocurrencies in your Wallet.

8. Transmission delays

Wintermute does not have any control over transaction times for the Cryptocurrency Network and there may be instances where transaction times may take longer than usual.

As such, you accept the risk that an Order facilitated by Wintermute may be delayed and you confirm that you will not hold Wintermute responsible for any losses, damages or injury arising out of or related to such delay.

9. Cancellations and refunds

Once you have placed an Order, it cannot be cancelled or recalled. All Orders are final and cannot be refunded. Once an Order has been initiated from a Wallet, it cannot be recalled or retrieved under any circumstances.

You hereby agree that all sales of Cryptocurrency are final and you will not be entitled to any credit or refund. Wintermute's obligation towards you will be absolutely discharged upon delivery of the Cryptocurrency to your Wallet or fiat funds to your bank account and you shall have no claim or right against Wintermute upon such delivery.

Please also note that Cryptocurrency transactions are irreversible. It is your sole responsibility to be vigilant of any fraud or mistake and to keep your private key(s) safe. Wintermute will not issue refunds, regardless of whether you were the victim of fraud, mistake or loss of private key(s).

10. Suspension, termination and cancellation

Wintermute may: (a) refuse to complete, or block or cancel an Order you have authorised; (b) suspend, restrict, or terminate your access to any or all of the Services; and/or (c) deactivate or freeze your Wintermute Account with immediate effect for any reason, including but not limited to where:

  • we reasonably believe that we need to do so in order to protect us or our reputation;
  • we are, in our reasonable opinion, required to do so by applicable law (including the laws of England and Wales), regulation or any court or other authority to which we are subject in any jurisdiction;
  • we reasonably suspect you of breaching this Agreement;
  • we have concerns that a transaction is erroneous or about the security of your Wintermute Account or we suspect the Services are being used in a fraudulent or unauthorised manner;
  • we suspect money laundering, terrorist financing, fraud, or any other financial crime;
  • use of your Wintermute Account is subject to any pending litigation, investigation, or government proceeding and/or we perceive a heightened risk of legal or regulatory non-compliance associated with your Wintermute Account activity;
  • you take any action that seeks to circumvent our controls such as opening multiple Wintermute Accounts or abusing promotions which we may offer from time to time;
  • you fail to provide documentation that Wintermute (or any third party whose services we use in providing the Services to you under this Agreement) reasonably requires in order to comply with its obligations under applicable laws and regulations or to verify your identity and/or funding sources to Wintermute satisfaction;
  • Wintermute reasonably believes that it is necessary or desirable to do so in order to protect the security of the Account, including circumstances where any Account details may have been lost or stolen.

In the case of any such suspension, Wintermute shall make reasonable efforts to inform you about it, provided that such disclosure:

  • is not in breach of any applicable law or regulation and does not contravene the instruction of any competent authority or regulator; and
  • would not compromise Wintermute's security measures.

Wintermute shall not be liable to you for any losses you may suffer as a result of any reasonable action it takes to suspend the Account or withhold settlement of a Cryptocurrency Order in accordance with this clause 10.

Where the reasons for Wintermute's actions under this clause 10 cease to exist, Wintermute may, at its discretion, either reinstate your access to the Account and Services and/or issue you with new Account details. Wintermute reserves the right to ask you to re-complete the Account opening procedures as outlined in this Agreement and to resolve any open issues with your Account before a restriction can be removed.

Notwithstanding the above, we may suspend, restrict, or terminate your access to any or all of the Services and/or deactivate or cancel your Wintermute Account, without reason by giving you at least three (3) Business Days' notice.

You will also be able to cancel your Wintermute Account at any time and free of charge, and will only be required to pay for those Services used that are subject to charges. If any Order is in a pending status at the time your Wintermute Account is cancelled or suspended, such Order will be completed before cancellation or suspension is effected.

You may not cancel your Wintermute Account to evade an investigation or avoid paying any amounts otherwise due to Wintermute. In the event that we terminate your access to the Services, or deactivate or cancel your Wintermute Account, or either we or you terminate this Agreement, you will remain liable for all amounts due under this Agreement prior to this, including all fees and charges.

11. Taxes

You are responsible for determining whether, and to what extent, any taxes apply to any transactions associated with the Services.

You must withhold, collect, report and remit the correct amounts of taxes to the appropriate tax authorities. We are not responsible for collecting these from you, for making any payments on your behalf, or for providing any reports relating to tax.

12. Data protection law

We are committed to keeping your personal information safe. We process personal information in accordance with applicable data protection legislation.

Please read our privacy policy to understand how we use and protect the information you provide us. A copy of our privacy policy can be accessed here: https://www.wintermute.com/privacy-policy

13. Liability

Neither Wintermute, nor any of its directors, employees or agents, shall be liable for any loss or damage sustained by you as a direct or indirect result of the provision by Wintermute of its Services, save that nothing in this Agreement shall exclude or restrict any liability of Wintermute resulting from:

  • death or personal injury;
  • for fraud, fraudulent misrepresentation or fraudulent misstatement; and/or
  • any statutory liability not capable of limitation.

Wintermute shall not be liable for loss of profits, loss of opportunity, loss of business, loss of savings, loss of goodwill, loss of Cryptocurrency, claims by third parties, loss of anticipated savings (whether direct or indirect) or for any type of special, direct, indirect or consequential loss howsoever caused, even if caused by Wintermute's negligence and/or breach of contract and even if such loss was reasonably foreseeable or Wintermute had been advised of the possibility of such loss.

Wintermute disclaims all liability associated with the use of Cryptocurrencies, including:

  • unknown inherent technical defects;
  • regulatory or legislative changes; and
  • currency fluctuation

Wintermute shall not bear any liability for any damage or interruptions caused by any computer viruses, spyware, scareware, Trojan horses, worms or other malware that may affect your computer or other equipment, or any phishing, spoofing or other attack. It is your responsibility to use a reputable and readily available virus screening and prevention software. You should also be aware that SMS and email services are vulnerable to spoofing and phishing attacks and should use care in reviewing messages purporting to originate from Wintermute.

You indemnify and hold us, our subsidiaries, members, directors, partners, officers, employees, contractors and agents harmless from and against any loss, liability, claim, demand, damages, costs, expenses (including legal fees) which may arise from or in connection with the Services, any content on the Services shared by you or other users, any third party websites or resources found through the services, any users of the services, or any breach of this Agreement, applicable laws or any law or regulation in any jurisdiction.

Except for the express statements set forth in this Agreement, you hereby acknowledge and agree that you have not relied upon any other statement or understanding, whether written or oral, with respect to your use and access of the Services and Site.

14. Warranties and representations

By agreeing to this Agreement, you represent, warrant and undertake to us that:

  • you have full power and authority to enter into this Agreement;
  • you understand and acknowledge that we do not warrant that any of the Services are suitable or appropriate for your needs and that you must take your own independent legal and other advice on such Services;
  • you are entering into this Agreement as principal and not on behalf of any third party;
  • you will not violate any applicable laws by entering into this Agreement or receiving the Services provided under it;
  • you will not facilitate any viruses, malware, worms, trojan horses or some other computer programming routines that may damage, corrupt, disrupt, misuse or gain unauthorised access to any data, system information or Services;
  • funds or Cryptocurrencies transferred to a Wallet or any sub-Wallet have been acquired lawfully;
  • you will not use an anonymizing proxy, or any other automatic devices, spider or manual processes to copy or monitor our websites without our prior written permission;
  • you will not harass and/or threaten our employees, agents, or other users;
  • you understand and acknowledge that while we make reasonable endeavours to ensure the accuracy of the information that we provide, and which in turn, is provided to you, neither we nor any of our directors, employees or agents make any representation or warranty, express or implied, as to the accuracy or completeness of such information;
  • any information provided by you to Wintermute under this Agreement is true, complete, accurate, up to date and not misleading; and
  • you shall provide all assistance reasonably requested by Wintermute to enable Wintermute to comply with its obligations under this Agreement.

The Services are provided on an "as is" and "as available" basis, with no further promises made by us around availability of the Services. Specifically, we do not give any implied warranties of title, merchantability, fitness for a particular purpose and/or non-infringement. We do not make any promises that access to the Site, any of the Services, or any of the materials contained therein, will be continuous, uninterrupted, timely, or error-free.

Wintermute makes no representation or warranty that the Services are applicable or appropriate for use by you and it is your responsibility to ensure you comply with any applicable laws.

15. Right of withdrawal

You have 14 (fourteen) calendar days to exercise your right of withdrawal from this Agreement, without having to justify any reason or pay any penalty. This withdrawal period begins on the day after the date that your application is accepted by us.

We will not normally provide the Services during the withdrawal period. Any Services or Orders which are fully performed before a withdrawal cannot be reversed.

You must notify your withdrawal request to us within the allotted period by email to support@Wintermute.com.

If you exercise your right of withdrawal, this Agreement will be terminated at no cost to you.

16. Protection

When you buy Cryptocurrency through Wintermute, it will not be protected by the Financial Services Compensation Scheme and you will not have recourse to the Financial Ombudsman Service.

17. Term

This Agreement will commence in the manner set out in clause 1 and will continue unless either party notifies the other of termination, in writing, in accordance with this Agreement.

This Agreement can be terminated immediately by the Customer providing written notice to Wintermute.

This Agreement can be terminated by Wintermute in accordance with all the provisions of this Agreement.

18. Changing These Terms

We may change these terms at any time for any reason, including (without limitation):

  • to comply with or reflect a change in Applicable Law or a decision by a relevant ombudsman or regulator;
  • to make them more favourable to you or to correct a mistake or oversight (provided that any correction would not be detrimental to your rights);
  • to provide for the introduction of new systems, Services, procedures, processes and/or products or to incorporate such changes in technology as we deem necessary (provided in each case any change would not be detrimental to your rights); or
  • to remove an existing Service, provided we have given you appropriate notice of its removal in accordance with this Agreement.

We will endeavour to provide notice of any amendment to you in advance by emailing it to you, indicating when the revised Agreement will become effective. Although we will endeavour to provide you with advance notice where possible, where lawful we may indicate that the revised Agreement shall be effective immediately.

Whether we have provided email notice of such amendment in advance to you or not, we will notify you of any changes to this Agreement on your first use of the Services after any amendment. You will be deemed to have accepted the changes if you continue to use the Services. If you do not accept the changes, you should terminate the Agreement in accordance with section 20.2, close your Wintermute Account, and cease using the Services.

An up to date copy of these terms is always available on our Website.

19. Security

You will be provided with security details from us which will be needed in order for you to access your Account with us. You must keep all such security details (including usernames and passwords) private and not share such details with any third party.

You must monitor your Account and read all messages that have been sent to you. If you suspect that any feature of your Account (for example login details, password or other security feature) has been lost, stolen, misappropriated, used without authorisation or otherwise compromised, you must contact us immediately notifying us of such action and you agree to change your password immediately if necessary.

We will never ask you to share your password with us or to any third party and you must never disclose this to anybody. It is advised that in order to keep your Account safe, you change your password regularly.

You must also ensure that your registered email account(s) are secure and can only be accessed by you, as your email address(es) may be used in the process of resetting passwords or we may send communications to your email account(s) regarding the security of your Account. In case any of the email addresses registered with your Account are compromised, you should immediately contact us.

20. Force majeure

Except as set out otherwise, we will be liable for any loss caused directly or indirectly from circumstances not within its control, including but not limited to acts of God, government restrictions, exchange or market rulings, actions affecting securities, clearing or commodity exchanges including suspensions of trading or extensions of trading hours, dealing cut-off times and holidays, acts of civil or military authority, national emergencies, natural disasters, wars, riots or acts of terrorism, industrial disputes, acts or regulations of any governmental or supranational bodies and authorities or the failure or malfunction of any telecommunication or computer service.

21. Notices

All notices and communications pursuant or in connection with this Agreement:

  • Must be in English, in writing and legible (you confirm by signing this Agreement that you possess proper knowledge and understanding of the English language);
  • Must be delivered and/or sent to us to one of the following addresses:
    • Mailing Address: Colegrave House, 70 Berners Street, London, Westminster, W1T 3NL, United Kingdom, or
    • Email address: support@Wintermute.com
    or at another address (within the United Kingdom) as we may from time to time notify you; and
  • Will be delivered or sent to you at the postal address or email address that you have provided to us in connection with this Agreement.

The parties acknowledge that any notice or other communication will be deemed to be given as follows:

  • If delivered by hand, at the time and on the date of delivery if delivered during a Business Day, or at the start of the next Business Day if delivered at any other time;
  • If sent by post to and from a place within the United Kingdom, at the start of the second Business Day after it was put in the post;
  • If sent by post to or from a place outside the United Kingdom, at the start of the fifth Business Day after it was put in the post; or
  • If sent by email, at the time and on the date of transmission if transmitted during normal office hours (09:00-17:30) on a Business Day (local time at the place of receipt) and, in any other case, at the start of the Business Day following the date of transmission.

This clause will not apply to the service of any legal proceedings or other documents in any legal action by the parties. Wintermute will not accept service of proceedings or any legal action by email from you or any third party.

We may (where allowed to do so by law) communicate with you by posting information in your Account or on the Site, in which case the information will be treated as received by you when it is posted by us.

If you have any feedback or questions contact us via our Customer support email address at support@Wintermute.com. Please provide your name, address, and any other information we may need to identify you, your Account, and the Order on which you have feedback or questions.

For any complaint relating to the Services, you are advised to contact support@Wintermute.com. Should we receive a complaint from you, we will carry out an independent investigation of your complaint and will provide you with a written response. We will aim to respond to you within thirty (30) days of receipt of your written complaint with our final response.

22. General

You must comply with all applicable laws, regulations, licensing requirements and third party rights (including, without limitation, data privacy laws) in your use of the Services.

"Wintermute", Wintermute.com and all logos related to the Services or displayed on the Site are trademarks or registered marks of Wintermute or its licensors. You may not copy, imitate or use them without our prior written consent or any third party's copyright, trade secret, patent or other intellectual property rights, or rights of publicity or privacy.

Your use of the Services and the Site is subject to international export controls and economic sanctions requirements. By using the Services to send, buy, or sell Cryptocurrencies, you agree that you will comply with those requirements.

You are not permitted to acquire Cryptocurrency or use any of the Services through the Site if:

  • you are in, under the control of, or a national or resident of Cuba, Iran, North Korea, Sudan, or Syria or any other country subject to United States embargo, UN sanctions, the European Union or HM Treasury's financial sanctions regimes (each a "Sanctioned Country"), or if you are a person on the U.S. Treasury Department's Specially Designated Nationals List or the U.S. Commerce Department's Denied Persons List, Unverified List, Entity List, or the EU or HM Treasury's financial sanctions regime (a "Sanctioned Person"); or
  • you intend to supply any acquired or stored Cryptocurrency or Services to a Sanctioned Country (or a national or resident of a Sanctioned Country) or Sanctioned Person.

Copies of the most up-to-date version of the Agreement will be made available in the Site at all times and will be provided to you by email on request.

Nothing in this Agreement shall be deemed or is intended to be deemed, nor shall it cause, either you or Wintermute to be treated as partners or joint ventures, or either you or Wintermute to be treated as the agent of the other.

If you receive information about another user through the Services, you must keep the information confidential and only use it in connection with the Services. You may not disclose or distribute a user's information to a third party or use the information except as reasonably necessary to carry out a transaction and other functions reasonably incidental thereto such as support, reconciliation and accounting unless you receive the user's express consent to do so. You may not send unsolicited communications to another user through Wintermute.

You are responsible for keeping your contact information, including your email address, up to date in your Wintermute Account profile in order to receive any notices or alerts that we may send you (including notices or alerts of actual or suspected Security Breaches).

This Agreement (including documents incorporated by reference herein) comprise the entire understanding and agreement between you and Wintermute as to the subject matter hereof, and it supersedes any and all prior discussions, agreements and understandings of any kind (including without limitation any prior versions of this Agreement), and every nature between and among you and Wintermute.

Section headings in this Agreement are for convenience only and shall not govern the meaning or interpretation of any provision of this Agreement.

This Agreement is personal to you and you cannot transfer or assign your rights, licenses, interests and/or obligations to anyone else. We may transfer or assign our rights licenses, interests and / or our obligations at any time to any persons, including but not limited as part of a merger, acquisition or other corporate reorganisation involving Wintermute, provided that this transfer or assignment does not materially impact the quality of the Services you receive. Subject to the foregoing, this Agreement will bind and inure to the benefit of the parties, their successors and permitted assigns.

If any provision of this Agreement is determined to be invalid or unenforceable under any applicable law, this will not affect the validity of any other provision. If any provision is found unenforceable, the unenforceable provision will be severed, and the remaining provisions will be enforced.

We may not always strictly enforce our rights under this Agreement. If we do choose not to enforce our rights at any time, this is a temporary measure and we may enforce our rights strictly again at any time.

This Agreement and any information or notifications that you or we are to provide should be in English.

In the event that Wintermute is acquired by or merged with a third party entity, we reserve the right, in any of these circumstances, to transfer or assign the information we have collected from you and our relationship with you (including this Agreement) as part of such merger, acquisition, sale, or other change of control.

Unless otherwise stated, nobody else has any rights under this Agreement. This Agreement is between you and us. No other person shall have any rights to enforce any of its terms including under the Contracts (Rights of Third Parties) Act 1999.

All provisions of this Agreement which by their nature extend beyond the expiration or termination of this Agreement, including, without limitation, the Sections relating to suspension or termination, Wintermute Account cancellation, debts owed to Wintermute, general use of the Site, disputes with Wintermute, and general provisions will continue to be binding and operate after the termination or expiration of this Agreement.

This Agreement will be governed by, and construed in accordance with, English law and, subject to any overriding legal requirements, the courts of England and Wales will have non-exclusive jurisdiction to settle any disputes. If you live in Scotland or Northern Ireland, you can bring legal proceedings in your local courts or the courts of England and Wales.

This Agreement and any information or notifications that you or we are to provide will be in English.